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CRA notes that a capital gain’s geographic source for Canadian FTC purposes was re-sourced to Australia under the Treaty-source rule

Summary of 26 November 2020 STEP Roundtable, Q.4 under Treaties – Income Tax Conventions – Art. 24. ...

CRA is examining whether a server used in cryptocurrency mining is a PE

Although this response was given in a GST/HST context, the same issue would arise regarding the application of income tax conventions. ...

CRA determined that a Singapore corporation was a resident there for Treaty purposes – even though it was subject to tax on a territorial basis - provided its CMC was there

Summary of 25 November 2021 CTF Roundtable, Q.4 under Treaties – Income Tax Conventions – Art. 4. ...

Canadian residents generally are better off investing in a portfolio that may include Canadian companies through a partnership rather than an LLC

Summary of Nakul Kohli and Jiani Qian, “Canadian Residents Earning Income Through Non-Resident US LLCs,” Canadian Tax Focus, Vol. 12, No. 1, February 2022, p. 10 under Treaties – Income Tax Conventions – Art. 4. ...

CRA indicates that “habitual abode” is determined in context based inter alia on relative stays and nature of activities

Summaries of 17 May 2022 IFA Roundtable, Q.1 under Treaties- Income Tax Conventions – Art. 4 and ITA s. 2(1). ...

CRA notes that around half of its recent MAP cases resulted in full relief

Summary of 17 May 2022 IFA Roundtable, Q.13 under Treaties – Income Tax Conventions – Art. 26. ...

CRA finds that where a UK company remotely operated crypto-mining equipment located on a Canadian host company’s premises, the equipment constituted a Canadian PE

Summary of 29 November 2022 CTF Roundtable, Q. 7 under Treaties – Income Tax Conventions – Art. 5. ...

Finance confirms that Pillar 2 is on track

The legislation is being drafted using Canadian legislative drafting conventions, but seeks to follow the OECD model closely. ...

CRA indicates that CPP and OAS payments are treated as pensions and social security payments under the Canada-Italy Treaty

Summary of 6 April 2023 Internal T.I. 2022-0929731I7 under Treaties – Income Tax Conventions – Art. 18. ...

CRA indicates that an exceptional COVID-related withdrawal from a Chilean pension plan qualified as an exempted pension under the Canada-Chile Treaty

Summary of 12 December 2023 External T.I. 2021-0881541E5 under Treaties – Income Tax Conventions – Art. 18. ...

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